The privacy of children who join our pre-teen groups is our highest priority. As a nonprofit that provides supportive services to children under 13 we believe that the Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) do not apply to Gender Spectrum. Nevertheless, we have outlined here our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”)to inform parents and legal guardians (as used in this policy, “parents”).

Our website, Lounge, and other services are intended for those 13 and over, and children under 13 are not permitted to use them. Children ages 11-12 may participate only in our pre-teen groups. In order to participate in our pre-teen groups, children use Zoom, a third-party online conferencing tool. It is Gender Spectrum’s policy to verify parental consent concerning collection, use and disclosure of children’s information by asking parents to print, sign and return pre-teen group verification and consent forms to us.

This policy notifies parents of:

The types of information that may be collected from children.

How we use the information we collect.

Our practices for disclosing that information.

Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.

All operators that collect or maintain information from children under 13 through Gender Spectrum’s services.

This policy only applies to children under the age of 13 and supplements our general privacy policy, which is available at https://genderspectrum.org/privacy. Only our general privacy policy applies to teens and adults.

Terms that are defined in the general privacy policy have the same meanings as used in this Privacy Policy re: Children Under the Age of 13.

Information We Collect from Children

We only collect as much information from parents about a child as is reasonably necessary for the child to participate in the pre-teen groups, and we do not condition childrens’ participation on the disclosure of more personal information than is reasonably necessary.

Information We Collect Directly

When a child wants to participate in the pre-teen discussion group, we ask parents to provide (via a web form) the following required information about themselves: first and last name, email, address, relationship to the youth, how you heard about the discussion group, and a phone number. We ask parents to provide the following required information about the child: name, birth year, and birth month. In addition, we solicit a variety of optional information on the form, including gender identity of the child, racial/ethnic background of the person filling out the form, and desired topics to be addressed in the discussion group. We specify whether information is required or optional when we request it.

We enable children enrolled in the pre-teen discussion group to communicate with others on or through the Service through audiovisual means, including telephone and video chats through Zoom. The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is shared on the calls, and we do not control the actions of third parties (including other participants on the call) with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of social features.

Automatic Information Collection

Zoom uses technology to automatically collect information from users, including children, when they join and participate in our groups. The information Zoom may collect is described in their privacy policy, cookie policy and related terms and conditions. When your child participates in a Zoom discussion, Zoom provides us with certain information, including

information (including email address) of call participants, how long participants stayed on the call, and the ability to download the chat log from the call.Because we do not permit children to use our website, lounge, or other online resources beyond the pre-teen discussion group, we do not automatically collect other information about your child. Use of our website by your child is not necessary for participation in the pre-teen group.

to alert parents or others if a child expresses self-harming thoughts or behaviors or needs additional mental health support

We use the information we collect to improve our Service and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.

Store information about the child’s preferences, allowing us to customize the content according to individual interests.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users, including information that does not identify any individual or device. In addition, we may disclose children’s personal information:

To third parties (including discussion group facilitators and technology service providers such as Form Assembly for group sign-ups, and Zoom for video conferences) to support the internal operations of our Service. We do not authorize such third parties to use this information, except to provide us with their service pursuant to written terms and policies.

If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Gender Spectrum, our customers or others, including to:

protect the safety of a child;

protect the safety and security of the Service; or

enable us to take precautions against liability.

To law enforcement agencies or for an investigation related to public safety.

In addition, if Gender Spectrum is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gender Spectrum’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Social Features

Zoom offers social features, including chat, teleconferencing, and videoconferencing that enable children to communicate with others through the Service during the pre-teen groups. We do not control the types of information your child can share, send or post through them. We encourage parents to educate their children about safety online and to carefully monitor their children’s use of social features to ensure they do not disclose their personal information through them.

Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.

Sending us an email at [[email protected] . To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Operators That Collect or Maintain Information from Children

FormAssembly (used to collect sign-up information) may collect information provided by parents about children

Salesforce (used to store user information)-only the child’s last name is entered in Salesforce, no first name. All other data is that associated with the parent or guardian.

We may amend our Privacy Policy re: Children Under the Age of 13 at any time, but if the changes are material we will make such changes in accordance with applicable law, and we will make reasonable efforts to provide prior notice. We ask that parents keep us informed of their current email address.